View source for AEP-NRC-2012-83, Communications Assessment Requested by Nuclear Regulatory Commission Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulation 50.54(f) Regarding Recommendation 2.1, 2.3, and 9.3.

{{Adams
| number = ML12318A176
| issue date = 10/31/2012
| title = Communications Assessment Requested by Nuclear Regulatory Commission Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulation 50.54(f) Regarding Recommendation 2.1, 2.3, and 9.3.
| author name = Carlson M
| author affiliation = Indiana Michigan Power Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000315, 05000316
| license number = 
| contact person = 
| case reference number = AEP-NRC-2012-83
| document type = Letter type:AEP, Report, Miscellaneous
| page count = 45
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:INDIANA                                                                                  Indiana Michigan Power MICHIGAN                                                                                 Cook Nuclear Plant 1POWER0                                                                                One Cook Place Bridgman, MI 49106 A unit ofAmerican Electric Power                                                          Indiana Michiga nPower.com October 31, 2012                                                               AEP-NRC-2012-83 10 CFR 50.54(f)
Docket No.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 Communications Assessment Requested by Nuclear Regulatory Commission Letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dal-ichi Accident," dated March 12, 2012.

==References:==
: 1.       Letter from E. J. Leeds and M. R. Johnson, U.S. Nuclear Regulatory Commission (NRC), to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012, (ML12056A046).
: 2.        Letter from J. P. Gebbie, Indiana Michigan Power Company (A&M) to NRC Document Control Desk, "60-Day Response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dal-Ichi Accident; dated March 12, 2012," dated May 11, 2012 AEP-NRC-2012-34.
: 3.        Letter from P. S. Tam, NRC, to L. J. Weber, I&M, "Review of 60-Day Response to Request for Information Regarding Recommendation 9.3 of the near-Term Task Force Related to the Fukushima Dai-ichi Nuclear Power Plant Accident (TAC Nos. ME8683 and ME8684)," dated June 8, 2012, (ML12145A640).
: 4.        Letter from D. L. Skeen, NRC, to S. Perkins-Grew, Nuclear Energy Institute (NEI), "U. S.
NRC Review of NEI 12-01, 'Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,' Revision 0, dated May 2012,"
dated May 15, 2012, (ML12131A043).
14-Y-95

U. S. Nuclear Regulatory Commission                                          AEP-NRC-2012-83 Page 2 On March 12, 2012, the NRC staff issued Reference 1, a Request for Information pursuant to 10 CFR 50.54(f), to I&M, the licensee for the Donald C. Cook Nuclear Power Plant (CNP) Units 1 and 2. Enclosure 5 of the letter contained specific Requested Actions and Requested Information associated with Recommendation 9.3 for Emergency Preparedness (EP) programs.
Specifically, I&M was requested to assess the means to power communications equipment onsite and offsite during a prolonged station blackout (SBO). By Reference 2, I&M provided a response to the Request for Information that proposed an alternative course of action and estimated completion date. I&M indicated that the communications assessment, prepared per the guidance of NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," and an implementation schedule of the time needed to implement the results of the communications assessment would be provided to the NRC by October 31, 2012. By Reference 3, the NRC agreed to the alternative course of action. to this letter provides an affirmation. Enclosure 2 provides the communications assessment. Enclosure 3 provides the implementation timeline.
This letter contains no new or revised regulatory commitments. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.
Sincerely, Michael H. Carlson Vice President - Site Support Services MCS/kmh

==Enclosures:==
: 1. Affirmation
: 2. Communications Assessment
: 3. Implementation Timeline

U. S. Nuclear Regulatory Commission                AEP-NRC-2012-83 Page 3 c:     C. A. Casto, NRC Region III J. T. King, MPSC S. M. Krawec, AEP Ft. Wayne, w/o enclosures MDEQ - RMD/RPS NRC Resident Inspector T. J. Wengert, NRC Washington DC to AEP-NRC-2012-83 AFFIRMATION AFFIRMATION I, Michael H. Carlson, being duly sworn, state that I am Vice President - Site Support Services of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth herein pertaining to I&M are. true and correct to the best of my knowledge, information, and belief.
Indiana Michigan Power Company Michael H. Carlson Vice President - Site Support Services SWORN TO AND SUBSCRIBED BEFORE ME THIS 5 &      DAY OF 06Vb&e(                ,2012 Notary P    lic My Commission Expires          1 - 1\_ \
to AEP-NRC-2012-83 Communications Assessment to AEP-NRC-2012-83 Bridgman, Michigan Berrien County to AEP-NRC-2012-83 Table of Contents 1 . P u rp o se ..................................................................................................................... 1 2 . B a c kg ro u n d ................................................................................................................ 1
: 3. Methodology ..............................................................................................................           1
: 4. Assumptions and Limitations ........................................                                                                 2
: 5. Assessment Sum mary ..........................................................................................                       4
: 6. Recom m endations ..................................................................................................                 5
: 7. References .................................................................................................................         6 Appendix A - Assessment (tabular form) ...................................................................                              7 Appendix B - NEI 12-01 Roll-up ................................................................................                        22 to AEP-NRC-2012-83
: 1.      Purpose This report documents the assessment of the Donald C. Cook Nuclear Plant's (CNP) communication capabilities performed in accordance with Nuclear Energy Institute (NEI) 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities", Revision 0, dated May 2012. This assessment is completed for Unit 1 and Unit 2.
: 2.      Background Based on the adverse effects of the March 11, 2011, Tohoku earthquake and subsequent tsunami on the Fukushima Dai-lchi Nuclear Power Plant, the United States Nuclear Regulatory Commission (NRC) issued a request for information (RFI) in accordance with 10 CFR 50.54(f) to Indiana Michigan Power Company (I&M), the licensee for the CNP, entitled "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," dated March 12, 2012. In the RFI, the NRC requested that I&M assess their current communications systems and equipment used during an emergency event given a set of standard assumptions. The NRC also requested that consideration be given to any enhancements that may be appropriate for the emergency plan with respect to communications requirements of 10 CFR 50.47, Appendix E to 10 CFR 50, and the guidance in NUREG-0696. I&M was also to consider the means necessary to power the new and existing communications equipment during a multi-unit event, with a loss of all AC power.
I&M's objective is to maintain the capability to perform critical communication during and following an event that results in an extended loss of AC power. NEI 12-01 provides criteria for assessing the availability of communication systems and equipment necessary for implementation of emergency planning standard requirements.
Communications capabilities that support implementation of mitigation strategies and repair actions intended to maintain or restore the functions of core cooling, containment, and spent fuel pool cooling are also to be assessed.
: 3.       Methodology The CNP communications assessment is based on the methodology set forth in NEI 12-01. More specifically, this assessment is based on NEI 12-01 Section 2, Assessment Assumptions, and NEI 12-01 Section 4, Communications During an Extended Loss of AC Power.
In order to perform the methodology in NEI 12-01,' the following steps were performed:
: 1. Discussed the communications            assessment      methodology   with   CNP stakeholders to ensure plant objectives are met.
1 to AEP-NRC-2012-83
: 2. Reviewed plant documentation related to CNP's Emergency Plan Procedures.
: 3. Reviewed CNP-specific responses to INPO IER 11-4.
: 4. Completed facility discussions with plant staff, including Information Systems (IT)/Communications Systems personnel.
: 5. Developed an assessment report containing the results of the assessment and recommendations.
: 6. Using the information gathered from the above steps, completed Appendix B of this document, which is based on the NEI communications assessment template.
: 4.       Assumptions and Limitations 4.1. The assumptions for this report are consistent with those presented in NEI 12-01.
4.1.1. A large-scale external event occurs that results in:
0    all on-site units affected
* extended loss of AC power 0    impeded access to the units 4.1.2. Initially, all on-site reactors are operating at full power and are successfully shut down.
4.1.3. A Hostile Action directed at the affected site does not occur during the period that the site is responding to the event.
4.1.4. The event impedes site access as follows:
A. Post event time: 6 hours - No site access. This duration reflects the time necessary to clear roadway obstructions, use different travel routes, mobilize alternate transportation capabilities (e.g., private resource providers or public sector support), etc.
B. Post event time: 6 to 24 hours - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation capabilities (e.g., private resource providers or public sector support).
C. Post event time: 24+ hours - Improved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment, supplies and large numbers of personnel.
2 to AEP-NRC-2012-83 4.1.5. Installed sources of AC power, including alternate AC power sources, are not available. These power sources are typically classified as safety-related or governed by augmented quality requirements.
4.1.6. Nonessential loads from DC battery buses are stripped in accordance with plant emergency or abnormal operating procedures, or other response guidelines to extend battery life.
4.1.7. Installed inverters and battery chargers remain available provided they are protected from external events consistent with the current station design. If the flood protection walk-downs performed in response to Near Term Task Force (NTTF) Recommendation 2.3 identify a lack of sufficient flood protection margin, the communications assessment should be updated to reflect the potentially lost equipment. A regulatory submittal of the updated assessment is not required.
4.1.8. On-site diesel fuel oil is available provided that it is stored in a manner protected from external events consistent with the current station design. If the flood protection walk-downs performed in response to NTTF Recommendation 2.3 identify a lack of sufficient flood protection margin, the communications assessment should be updated to reflect the potentially lost fuel oil. A regulatory submittal of the updated assessment is not required.
4.1.9. Portable equipment staged for implementation of accident management strategies (e.g., Severe Accident Mitigation Guidance (SAMG) and Extensive Damage Mitigation Guidelines (EDMG) may be used provided it is stored on-site; is reasonably protected from seismic, wind, and flooding events; is maintained through programmatic controls; and has implementing actions specified in existing procedures or guidelines. This includes use of portable AC and DC power sources.
4.1.10. On-site communications infrastructure remains available provided that the credited components are reasonably protected from seismic, wind, and flooding events; maintained through programmatic controls; have a power source consistent with the other assumptions in this section; and employed in accordance with implementing actions specified in existing procedures or guidelines.
4.1.11. Offsite infrastructure supporting communications systems is inoperable in the area surrounding the site (e.g., cellular telephone or off premise extensions (OPXs), telephone central office buildings, telephone lines, etc.). A licensee has two options for determining the affected area.
           "    Apply a default distance value, in all directions, of approximately 25 miles from the plant site, OR
           "    Develop a site-specific distance assumption and document the basis.
3 to AEP-NRC-2012-83 Communications infrastructure in locations beyond the area defined above is not-significantly impacted by the event.
4.1.12. Communications equipment located at an offsite response facility, and supplied from a backup power source, is assumed to be functional. The availability of this equipment must be determined in conjunction with Assumption 4.1.11, above. For example, a diesel generator-powered satellite telephone system at an Emergency Operations Center (EOC) located 4 miles from the plant would be available since the system does not rely upon ground-based communications infrastructure within the affected area. A land-line telephone in the same EOC would not be available due to local infrastructure impacts consistent with Assumption 4.1.10.
5.0     Assessment Summary Appendix A provides the assessment in tabular form.
The in-plant radio system is used extensively for a variety of emergency response purposes, including equipment operation, fire brigade, in-plant monitoring, etc. Under normal conditions, the in-plant radio system uses repeaters to ensure radio coverage throughout the plant. In addition, if the repeaters are not available due to loss of AC power, the radios can be operated for point-to-point communications, which may not ensure coverage throughout all areas of the plant. The public address (PA) and the voice powered phone system provide alternatives to the radios.
Communications with the off-site response organizations (OROs) utilize the on-site public branch exchange (PBX) telephone system and the public switched telephone network (PSTN). The Control Room currently has two direct outside lines to the PSTN that automatically bypass the PBX if it is out of service. These lines are not aerial during any portion of their route. However, as previouslydiscussed, the PSTN is assumed to be non-functional for purposes of this assessment. In the event of land-line telephone unavailability, communications can be carried out using the plant 450 MHz radios.
Assuming that the on-site repeater is unavailable, radio communications will be limited based upon line of sight and radio power. Additional communications capability is being provided by satellite telephones. Satellite telephones will be distributed to the State of Michigan, Berrien County Sheriff's Department and the Lake Township Fire Department.
Field Teams dispatched from the site use the 450 MHz radio system to communicate with the Emergency Operations Facility (EOF). The radios in the vehicles are powered by the vehicle's electrical system. With the postulated loss of AC power to the on-site repeater, these radios will be limited to point-to-point communications. Although this will limit the range, the teams can still be effective for providing measurements for dose projection tasks within limited distances from the site. As a backup to the radios, cell phones are provided for each vehicle. Again, based on the assumptions used for the assessment, the cell phone infrastructure is considered to be out of service. Satellite 4
to AEP-NRC-2012-83 telephones have been purchased and received at the site and will be provided to the Field Team vehicles.
: 6.      Recommendations Recommendations to further evaluate or enhance communications capabilities were developed as a part of the assessment.
6.1     Supplement direct telephone lines linking the CNP Emergency Facilities to the Lake Township Fire Department and the Berrien County and State of Michigan Emergency Operations Centers with satellite phones for the postulated loss of the public phone system infrastructure.
6.2     Evaluate off-site radio communications including:
a) Ability of existing 450 MHz trunked radios to function in "point-to-point" mode.
b) Mapping of radio reception in the Emergency Planning Zone (EPZ) and to the EOCs without the repeater in service.
c) Reasonable assurance of survivability for the off-site radio repeater and antennae.
The following actions related to communications will be evaluated as a part of CNP's mitigation strategies for beyond-design-basis events (FLEX) strategy:
6.3     Determine feasibility for the following future actions associated with FLEX:
: 1. Provide additional battery backup for the PA system.
: 2. Provide capability for hooking up alternate power generator for the intra-plant 450 MHz radio system
: 3. Provide capability for hooking up alternate power generator for the public address system.
: 4. Harden exterior antennae to the extent necessary to provide reasonable assurance of survivability.
: 5. Provide survivable offsite 450 MHz radio system (including repeater and antennae) or portable repeater equipment.
6.4     Provide alternate power supplies for the following             locations (assuming survivability):
a) EOF, which also has an existing diesel generator b) Operations Support Center (OSC) 6.5      Provide standalone uninterruptible power supply (UPS) units for equipment in the Emergency Operations Facility (EOF) and Technical Support Center (TSC) that 5
to AEP-NRC-2012-83 is needed to manage the emergency (computers, multi-line telephones and portable phones).
6.6    Provide a dedicated source of backup power (portable generator) for charging batteries for handheld radios.
6.7    Update training programs to address emergency communications equipment consistent with implementation of FLEX.
: 7. References 7.1. Cook Emergency Plan, Revision 30.
7.2. Emergency Plan Implementing        Procedure  PMP-2080-EPP-100,  Emergency Response, Revision 22.
7.3. Emergency Plan Implementing Procedure RMT-2080-EOF-001, Activation and Operation of the EOF, Revision 19.
7.4. Emergency Plan Implementing Procedure RMT-2080-ENC/JIC-001, Activation and Operation of the ENC/JIC, Revision 4.
7.5. Emergency Plan Implementing Procedure RMT-2080-OSC-001, Activation and Operation of the OSC, Revision 12.
7.6. Emergency Plan Implementing Procedure RMT-2080-TSC-001, Activation and Operation of the TSC, Revision 16.
7.7. NEI Template. Communications During an Extended Loss of AC Power Roll-Up Document. Revision 1, August 2012.
7.8. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, May 2012.
7.9    Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.
6 to AEP-NRC-2012-83 Appendix A - Assessment Table 1 Emergency Response Communication Systems (Current Capabilities including Satellite Phone Implementation)
Communications Systems/Equipment (with Emergency Plan            Alternate methods                     System/Equipment Description/Application cross-reference where applicable)
PA System
* PBX Telephone System         For all emergency classifications, all personnel within the Protected Area are notified of an emergency by recognizable Cook Emergency Plan (CEP),
* Commercial Telephone          alarms and/or verbal announcements over the plant PA Section F-Emergency                 System                        System. The PA system can be used by individuals in the Communications                                                    plant through PA system phones located in various plant
* ERO Pagers                   areas.
Emergency Plan Implementing Procedure (EPIP) PMP-2080-
* Company Intranet EPP-100, Emergency Response,        messages paragraph 1.3
* Company e-mail
* Voice Powered Phones
* Handheld radios (450 MHz)
* Handheld bullhorns 7
to AEP-NRC-2012-83 Appendix A - Assessment Table 1 Emergency Response Communication Systems (Current Capabilities including Satellite Phone Implementation)
Communications Systems/Equipment (with Emergency Plan             Alternate methods                      System/Equipment Description/Application cross-reference where applicable)
Plant PBX Telephone System
* Commercial Telephone          The PBX telephone system provides communication dSystem                       capability between telephones located within the plant by CEP FAA                             Sdialing                               the last four digits of the commercial phone number.
* Direct Dialing Lines         The PBX is used to connect the Control Rooms, Technical Support Center (TSC), EOF, Joint Information Center (JIC)
* Cellular telephones (Not      and Operations Support Center (OSC). The PBX telephone in the Emergency Plan)        system also provides for outside communications through interconnections with the commercial telephone lines. There
* Plant System Pagers          are currently 2 PBX locations. These are located in the Lakeside Office Building and Training Center. Both PBXs are equipped with backup batteries.
Wide Area Fiber Optic System     0  Cellular telephones (Not      This system provides communications connectivity to (Not in the Emergency Plan)         in the Emergency Plan)        extensions at CNP for communication with the CNP Emergency Response Facilities (ERF), Lake Township Fire 0  Satellite Phones (Not in      Department, Berrien County Emergency Operations Center, the Emergency Plan)           and the Michigan State Emergency Operations Center.
Commercial Telephone System      0  Cellular telephones (Not      This system provides standard commercial telephone service din the Emergency Plan)       through the public infrastructure, consisting of central offices CEP FAd                              iand                               the fiber line and microwave carrier. The commercial
* Satellite Phones (Not in      telephone system includes connections to PBX, emergency the Emergency Plan)           telephone system, dedicated lines to CNP ERFs and the Berrien County 911 Dispatcher. The commercial vendor provides primary and secondary power for their lines at their central office (CO).
8

Enclosure 2 to AEP-NRC-2012-83 Appendix A - Assessment Table 1 Emergency Response Communication Systems (Current Capabilities including Satellite Phone Implementation)
Communications Systems/Equipment (with Emergency Plan            Alternate methods                      System/Equipment Description/Application cross-reference where applicable)
Other telephones                 0   PBX                          There are two telephone lines in each Control Room that automatically bypass the plant PBX if it fails.
CEP, F.A.d
* Satellite Phones (Not in the Emergency Plan)
Nuclear Emergency Alarm          &deg;   PA Announcements             For all emergency classifications, all personnel within the System                                                            Protected Area, buildings in the Owner Controlled Area and
                                   &deg;  Pagers                       the Buchanan Office Building are notified of an emergency by EPIP PMP-2080-EPP-100,                                            recognizable alarms and/or verbal announcements over the Emergency Response,
* Handheld bullhorns           plant PA System. The evacuation alarm is generated by a
-paragraph 1.3                                                     solid state multi-frequency audio oscillator capable of producing distinctive tones which can be heard over all plant paging zones via the plant paging system.
Ring Down Telephone                 Commercial Telephone          Point to Point phones connected through the PBX and are "conference   lines" that automatically ring when any one of the EPIP PMP-2080-EPP-100,              System                        receivers is picked up. The direct lines are located in both Emergency Response,              0  Satellite Phones (Not in      Control Rooms, Central Alarm Station, Secondary Alarm Attachment 12 (Berrien County       the Emergency Plan)           Station, the EOF, and the Berrien County 911 Dispatcher.
Sheriff Notification).
RMT-2800-EOF-001, Activation and Operation of the EOF, Attachment 16 (County Communications) 9 to AEP-NRC-2012-83 Appendix A - Assessment Table 1 Emergency Response Communication Systems Current Capabilities including Satellite Phone Implementation)
Communications Systems/Equipment (with Emergency Plan            Alternate methods                     System/Equipment Description/Application cross-reference where applicable)
NRC Communications
             )         ETS          Plant Telephone System      Communications with the NRC Operations Center will be (ENS & HPN)                                                     performed via the NRC Emergency Notification System (ENS)
* Commercial Telephone         and Health Physics Network (HPN) circuits on the commercial CEP, F.1.f                         System                       telephone line. Information is normally communicated from an ERO-approved member prior to establishing an open ENS
* Cellular telephones (Not     and/or HPN line.
in the Emergency Plan)
ENS: Dedicated telephone equipment is in place between Control Room and the NRC, with an extension of that line in the TSC and EOF.
HPN: There is a separate dedicated telephone between the NRC, the TSC, and EOF for conveying health physics information to the NRC as requested or as an open line. In addition, NRC counterpart lines are located in the Control Room, TSC and EOF.
10 to AEP-NRC-2012-83 Appendix A - Assessment Table 1 Emergency Response Communication Systems (Current Capabilities including Satellite Phone Implementation)
Communications Systems/Equipment (with Emergency Plan             Alternate methods                      System/Equipment Description/Application cross-reference where applicable)
Facsimile (Fax) Communications    0  Commercial Telephone          Fax communications capability is provided via the PBX 3System                       telephone system between the Control Rooms, CNP ERFs, CEP Hd H.2.d and H.3.d               SyState                              of Michigan, and Berrien County Sheriff's offices.
lnternet/WebEOC (Not in EPIP PMP-2080-EPP-100,               the Emergency Plan)
Emergency Response, Attachments: 11 (MSP              0  Satellite Phones (Not in Notification) and 12 (Berrien        the Emergency Plan)
County Sheriff Notification).
EPIP RMT-2080-EOF-001, Activation and Operation of the EOF, Attachments: 15 (MSP Notification) and 16 (Berrien County Sheriff Notification).
ERO Pagers (Call Out)             0  ERO Pagers                    Paging is done at CNP through a commercial provider.
Telephones can also be used as a backup. The paging EPIP PMP-2080-EPP-100,
* Commercial Telephone          provider maintains antennas on local communications towers.
Emergency Response,                  System paragraph 3.1.9 0  Cell Phones (Not in the Emergency Plan)
Cellular Telephones               0  Commercial telephone          This system provides standard commercial telephone service asystem                       through the public infrastructure consisting of central offices, Not in Emergency Plan                sthe                               fiber line, microwave carrier, and commercial cell phone towers and repeaters.
11 to AEP-NRC-2012-83 Appendix A - Assessment Table 1 Emergency Response Communication Systems (Current Caoabilities including Satellite Phone IMolementation)
Communications Systems/Equipment (with Emergency Plan             Alternate methods                     System/Equipment Description/Application cross-reference where applicable)
Satellite Telephones             0   Plant PBX Telephone         Eighteen satellite phones have been purchased. The phones System                       have not been installed, but have been received and Not part of Emergency Plan                                       programmed.
a   Local Commercial Telephone System
* Cellular telephones (Not in the Emergency Plan)
Field Monitoring Team               Cellular telephones (Not     Teams are dispatched from the OSC. Handheld radios are Communications                      iin the Emergency Plan)      used purchasedfor communicating.
and will be installed Satellite phones   have Team been in both Field Monitoring CEP F.1.d                                                        vehicles.
12 to AEP-NRC-2012-83 Appendix A - Assessment Table 2 Emergency Response Communication Systems - Hazard Analysis (Current Capabilities including Satellite Phone Im lementation)
System/Equipment       Primary System     Protected from      Protected from        Protected from (with Emergency Plan cross-reference                           Simca Component          defined in          Flooding as defined   Wind as defined          Comments wherea       ce        Location             ned1-             in NEI 12-01          in NEI 12-01 where applicable)                         NEI  12-01 PA system /            Various plant            Yes                    Yes                 Yes      Powered from essential Emergency              locations                                                                    power bus.
Evacuation Alarm System EPIP PMP-2080-EPP-100, Emergency Response, paragraph 1.3 PBX Telephone          Lakeside Office            No                    No                 No       No protection System                 Building and                                                                 enhancements currently Training Center                                                              planned CEP, F.A.d Commercial             Interface                  No                   No                  No       Some phone lines are Telephone System       equipment                                                                    direct in dialing. These (Fiber to Central                                                            phones bypass the PBX CEP, F.1.d             Offices (CO).                                                                and go directly to Lakeside Office                                                              locations within the plant.
Building and                                                                 Powered by the PSTN CO Training Center)
Other telephone lines  Lakeside Office          Yes                   Yes                  Yes      There are two telephone Building and                                                                 lines in each Control CEP F.1.d              Training Center                                                              Room that automatically bypass the plant PBX if it fails.
13 to AEP-NRC-2012-83 Appendix A - Assessment Table 2 Emergency Response Communication Systems - Hazard Analysis (Current Capabilities including Satellite Phone Im lementation)
System/Equipment       Primary System     Protected from      Protected from        Protected from (with Emergency        Component          Seismic as          Flooding as defined   Wind as defined          Comments Location           defined in          in NEI 12-01          in NEI 12-01 where applicable)                         NEI 12-01 Nuclear Emergency      Various plant            Yes                    Yes                 Yes      Powered from essential Alarm System           locations                                                                    plant bus.
EPIP PMP-2080-EPP-100, Emergency Response, paragraph 1.3 Ring Down Telephone    Both Control              No                    No                  No       Point to point phones are Rooms, Central                                                               connected through the EPIP PMP-2080-         Alarm Station,                                                               PBX. They are EPP-100, Emergency     Secondary                                                                    "conference lines" that Response,              Alarm Station,                                                               automatically ring when Attachment 12          EOF, and 911                                                                 any one of the receivers (Berrien County        dispatch                                                                     are picked up. The direct Sheriff Notification).                                                                              lines are located in both Control Rooms, Central RT-2080-EOF-001,                                                                                    Alarm Station, Secondary Activation &                                                                                        Alarm Station, the EOF, Operation of the EOF,                                                                               and the Berrien County Attachment 16                                                                                       911 dispatcher.
(County Communications)
NRC Communications     Control Rooms            Yes                    Yes                 Yes      Powered from the CO.
(ENS & HPN) Phone      TSC                      Yes                    Yes                 Yes      Additional NRC Lines are Line/Circuit           EOF                       No                    No                  No       provided (counterpart lines).
CEP, F.1.f 14 to AEP-NRC-2012-83 Appendix A - Assessment Table 2 Emergency Response Communication Systems          - Hazard Analysis (Current Capabilities including Satellite Phone Implementation)
System/Equipment       Primary System    Protected from      Protected from        Protected from (with Emergency       Component          Seismic as          Flooding as defined   Wind as defined       Comments Location                              in NEI 12-01          in NEI 12-01 where applicable)                        NEI 12-01 Facsimile (Fax)       Control Rooms            Yes                    Yes                 Yes      Message sent via PBX Communications -      TSC                      Yes                    Yes                 Yes EOF/OSC,                  No                    No                  No CEP H.l.d, H.2.d and   ENC/JIC H.3.d EPIP PMP-2080-EPP-100, Emergency Response, Attachments: 11 (MSP Notification) and 12 (Berrien County Sheriff Notification)
EPIP RMT-2080-EOF-001, Activation and Operation of the EOF, Attachments: 15 (MSP Notification) and 16 (Berrien County Sheriff Notification).
15 to AEP-NRC-2012-83 Appendix A - Assessment Table 2 Emergency Response Communication Systems        -  Hazard Analysis (Current Capabilities including Satellite Phone Im lementation)
System/Equipment       Primary System    Protected from      Protected from         Protected from (with Emergency Plan                     Simca cross-reference        Component         defined in          Flooding as defined   Wind as defined         Comments Location                              in NEI 12-01           in NEI 12-01 where applicable)                        NEI 12-01 ERO Pagers (Call       OPX                     No                     No                   No      Paging is done by CNP Out)                                                                                               through a commercial provider. Telephones can also be used as a backup.
The paging provider maintains antenna on local communications towers. The commercial towers have been designed for severe weather and are equipped with an 8 hour battery Cellular Telephones    Various                  No                    No                   No      The Microwave tower has been designed for severe Not in Emergency                                                                                   weather and is equipped Plan                                                                                               with 8 hour batteries.
Satellite Telephones   Control Rooms           Yes                   Yes                   Yes     Battery Powered. Extra batteries and chargers are Not in Emergency       CNP ERFs                No                     No                   No      available.
Plan 16 to AEP-NRC-2012-83 Appendix A - Assessment Table 2 Emergency Response Communication Systems - Hazard Analysis (Current Capabilities including Satellite Phone Im lementation)
System/Equipment       Primary System       Protected from     Protected from        Protected from (with  Emergency Plan crossrEmergency        Cmoet               dfndi n Component           Sefinmic aFlooding            as defined  Wind as defined          Comments cross-reference        Location                                in NEI 12-01          in NEI 12-01 where applicable)                           NEI 12-01 Field Monitoring       EOF/ EP                    No                     No                 No       Teams dispatched from Team                   Vehicles                                                                      OSC. Handheld radios are Communications                                                                                       used for communicating.
Field Teams also have cell CEP, F.A.d                                                                                           phones. Satellite phones will be installed in both Field Monitoring Team vehicles.
Diesel Fuel Oil        Use existing              To be           To be determined          To be     Will be evaluated as a part Storage Areas used     diesel fuel oil        determined                                determined   of CNP's mitigation for fueling portable   storage tanks                                                                 strategies for beyond-equipment used for                                                                                   design -basis external communications                                                                                       events (FLEX) strategy Not in Emergency Plan 17 to AEP-NRC-2012-83 Appendix A - Assessment Table 3 Emergency Response Communication Systems - Power Supply Analysis (Current Capabilities including Satellite Phone Implementation)
System/Equipment         Primary Power       Alternate Power       Backup power                          Comments (with Emergency Plan     Supply (List the    Supply (List the     availability (e.g.,
cross-reference where    power source)       power source)        batteries, portable applicable)                                                       generators, etc.)
Yes/No Public Address (PA)      Critical Control    Emergency            Yes -Battery         No power supply enhancements currently System                   Room Power          Diesel               backup               planned.
CEP F.1.e Plant PBX Telephone      Battery             Yes - battery        Yes - battery        No power supply enhancements currently System                                       backup               backup               planned.
CEP F.1.e Commercial Telephone     PBX                 Yes - Battery        Yes - Battery        There are two PBX locations. One is System                                       backup               backup               located in the Lakeside Office Building and the other is in the Training Center.
CEP F.A.d Plant Radio Transmitter- OPX                 Emergency            Yes - Battery        System uses repeaters, satellite receivers Receiver System                              Diesel               backup               and comparators inside the plant. One additional repeater for offsite CEP F.A.d                                                                              communication is located at the OPX and has battery and generator backup Other telephone lines    CO                  CO                   Yes                  There are two telephone lines in each Control Room that automatically bypass CEP F.1.d                                                                              the plant PBX ifit fails.
Nuclear Emergency        Critical Control    Emergency            Yes - battery        No power supply enhancements currently Alarm System             Room power          diesel               backup               planned.
EPIP PMP-2080-EPP-100, Emergency Response, paragraph 1.3 18 to AEP-NRC-2012-83 Appendix A - Assessment Table 3 Emergency Response Communication Systems - Power Supply Analysis (Current Ca pabilities including Satellite Phone Implementation)
System/Equipment          Primary Power      Alternate Power       Backup power                       Comments (with Emergency Plan      Supply (List the   Supply (List the      availability (e.g.,
cross-reference where     power source)      power source)         batteries, portable applicable)                                                        generators, etc.)
Yes/No Ring Down Telephone       PBX                CO                    Yes                 The Ring Down phones are Point to Point Lines                                                                                  phones connected through the PBX and are "conference lines" that automatically EPIP PMP-2080-EPP-                                                                     ring when any one of the receivers is 100, Emergency                                                                         picked up. The direct lines are located in Response, Attachment                                                                   both Control Rooms, Central Alarm 12 (Berrien County                                                                     Station, Secondary Alarm Station, the Sheriff Notification).                                                                 EOF, and the Berrien County 911 Dispatcher.
RT-2080-EOF-001, Activation & Operation of the EOF, Attachment 16 (County Communications)
NRC Communications        CO                 Unknown               Unknown             No power supply enhancements currently planned.
Facsimile                 PBX                Battery back-up       Battery back-up     Uses PBX & PSTN Communications CEP H.l.d, H.2.d and H.3.d 19 to AEP-NRC-2012-83 Appendix A - Assessment Table 3 Emergency Response Communication Systems - Power Supply Analysis (Current Ca abilities includina Satellite Phone Implementation)
System/Equipment         Primary Power      Alternate Power       Backup power                         Comments (with Emergency Plan     Supply (List the   Supply (List the      availability (e.g.,
cross-reference where    power source)      power source)         batteries, portable applicable)                                                       generators, etc.)
Yes/No ERO Pagers (Call Out)    OPX                No                    Diesel generator    Paging is done by CNP through a and Battery         commercial provider. Telephones can also EPIP PMP-2080-EPP-                                                                    be used as a backup. The paging provider 100, Emergency                                                                        maintains antennas on local Response, paragraph                                                                   communications towers. The commercial
 .3.2.4                                                                                towers have been designed for severe weather and are equipped with an 8 hour battery.
Cellular Telephones      Cell Phone         AC Outlet             No                  Eighteen satellite phones have been Battery                                                      purchased and will be located in both Not in Emergency Plan                                                                 Control Rooms, Security (x4: Central Alarm Station, Secondary Alarm Station, and 2 mobile), TSC, Onsite Survey Teams (x2), EOF (x3: State Communicator, Incident Command Post, and Field Team Communicator), Offsite Survey TeamsNehicles (2), Lake Township Fire Department, and the Berrien County and State of Michigan Emergency Operations Centers.
20 to AEP-NRC-2012-83 Appendix A - Assessment Table 3 Emergency Response Communication Systems - Power Supply Analysis (Current Capabilities including Satellite Phone Implementation)
System/Equipment         Primary Power      Alternate Power       Backup power                         Comments (with Emergency Plan     Supply (List the   Supply (List the      availability (e.g.,
cross-reference where    power source)      power source)         batteries, portable applicable)                                                       generators, etc.)
Yes/No Satellite Telephones     Battery            Additional            Yes, portable       Eighteen satellite phones have been powered,           batteries             generators          purchased and will be located in both Not in Emergency Plan    recharges at                                                 Control Rooms, Security (x4: Central local power                                                  Alarm Station, Secondary Alarm Station, outlet                                                       and 2 mobile), TSC, Onsite Survey Teams (x2), EOF (x3: State Communicator, Incident Command Post, and Field Team Communicator), Offsite Survey TeamsNehicles (2), Lake Township Fire Department, and the Berrien County and State of Michigan Emergency Operations Centers.
Field Monitoring Team    Battery            Additional            Yes, portable       Portable generators are currently located Communications           powered,           batteries             generators          at the Bridgman material Center recharges at                                                 approximately 5 miles from the plant.
CEP F.1.d                local power outlet 21 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up NEI 12-01 Revision 0 (May 2012) 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.1     REQUIRED EMERGENCY COMMUNICATIONS CAPABILITIES Consistent with emergency planning standard requirements, communications systems and equipment associated with the following emergency response functions should be available during an extended loss of AC power. Availability should be determined after a review of existing capabilities and consistent with the assumptions listed in NEI 12-01, Rev. 0, Section 2. In particular, it is important that the primary and backup (if applicable) power source for each communications system or piece of equipment be identified.
End-point equipment identified for a communications link listed below should be used solely for the purpose indicated. For example, a satellite telephone assigned to the Control Room should not be credited for performing both Offsite Response Organization (ORO) and NRC notifications. When performing this assessment, consideration should be given to the desirability of providing some communications capabilities in alternate facilities at offsite locations instead of their normal locations in on-site facilities.
4.1.1   Notifications to, and communications with, OROs [per 10 CFR 50, Appendix E.IV.D and E.9.a]
Primary Method                                Backup Available            -Backup              Method(s)           Planned or             Refer to Emergency               Minimum           Primary Method          following            Method(s)            Available            Potential       Following Section for Additional E-Planin site Response Facility      Communications         Described               Assumed Large-Scale            E-Planin site Described                following Assumed           Improvement Identified?         Information Links Natural Event                                LSNE?
(LSNE)?
CEP     Room          1 per Control Room       Direct Phone               No                PSTN                  None           Satellite Phone             5.1 CEP FAAd1pe                   otrlRo                 Line EOF                                            Direct Phone 1 for the EOF         Di         ne              No                PSTN                  None           Satellite Phone             5.1 CEP F..d                                             Line 22 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.1.2    Notifications to, and communications with, the Nuclear Regulatory Commission (NRC) Headquarters Incident Response Center and the appropriate NRC Regional Office Operations Center [per 10 CFR 50, Appendix E.IV.D and E.9.d]
Primary Method                         Backup Backup          Method(s)          Planned or             Refer to EmergencyMinimum                          Primary Method         Available        Method(s)        Available           Potential       Following Section ResponsenFacity      Communications       Described in site      following    Described in site     following        Improvement         for Additional Response Facility              Links             E-Plan             Assumed E-Plan          Assumed            Identified?          Information LSNE?                              LSNE?
Control Room         1 per Control Room          FTS                  No             PSTN              None          Satellite Phone            5.2 for ENS CEP F.l.d             Communicator TSC              1 for ENS and HPN           FTS                  No             PSTN              None          Satellite Phone            5.2 Communicator CEP F.1.d EOF              1 for ENS and HPN           FTS                  No             PSTN              None          Satellite Phone            5.2 Communicator CEP F.1.d 23 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.1.3 Communications between licensee emergency response facilities [per 10 CFR 50 Appendix E.9.c. Additional links that support performance of critical response functions are also specified.] The minimum communications links to support this function are listed below by facility. For example, if the normally used telephone system cannot be restored to service, these links could rely upon some combination of radio, Voice powered and satellite-based communications systems.
Emergency               Minimum            Primary Method           Primary          Backup               Backup              Planned or             Refer to Response Facility   Communications Links       Described in site        Method         Method(s)            Method(s)              Potential            Following E-Plan             Available      Described in          Available            Improvement           Section for following      site E-Plan            following            Identified?           Additional Assumed                               Assumed                                    Information LSNE?                                 LSNE?
Control Room               2 per unit               PBX /          PA system and    PA system and         PA system and        Satellite Phones            5.3 Commercial            handheld     handheld radios      handheld radios CEP F.A.d                                      Phone Lines and           radios PA system------
TSC                 1 each for:                     PBX /          PA system and    PA system and         PA system and        Satellite Phones            5.3 Commercial            handheld     handheld radios      handheld radios Site Emergency             Phone Lines and           radios Emergency           Coordinator                   PA system

===Response===
Organization        Radiological Directory Section   Assessment 7 (Emergency        Coordinator Phone Numbers),
Section 8           Plant Evaluation Team (Emergency Plan Phone Use Key &     TSC Security Director Facility Maps) and Section 9       Board Writer (Communications in the ERO) 24 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up Emergency            Minimum       Primary Method         Primary         Backup         Backup          Planned or          Refer to Response Facility Communications Links Described in site      Method         Method(s)      Method(s)         Potential         Following E-Plan          Available      Described in     Available       Improvement        Section for following      site E-Plan     following        Identified?        Additional Assumed                         Assumed                            Information LSNE?                          LSNE?
OSC               1 each for:                PBX /       PA system and    PA system and  PA system and    Satellite Phones          5.3 Commercial         handheld     handheld radios handheld radios OSC Manager          Phone  Lines and        radios Emergency Rmesponse                                 PA system Response          Radiation Protection Organization      Director Directory Section 7 (Emergency      Board Writer Phone Numbers),
Section 8 (Emergency Plan Phone Use Key &
Facility Maps) and Section 9 (Communications in the ERO)
EOF               1 each for:          PBX /             Handheld        Handheld        None            Satellite Phones  5.3 Commercial        radios          radios Emergency         Emergency Director   Phone Lines and

===Response===
Organization      Operations Advisor   handheld radio Directory Section Dose Assessment 7 (Emergency Phone Numbers),   Reactor Physics Section 8         Analyst (Emergency Plan   Board Writer Phone Use Key &
Facility Maps) and Section 9 (Communications in the ERO) 25 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up Emergency            Minimum       Primary Method        Primary       Backup        Backup      Planned or        Refer to Response Facility Communications Links Described in site     Method       Method(s)    Method(s)      Potential       Following E-Plan          Available    Described in   Available    Improvement      Section for following    site E-Plan    following    Identified?     Additional Assumed                     Assumed                       Information LSNE?                       LSNE?
Emergency News    1 each for:          PBX /             None          None          None         TBD            N/A Center (ENC) /                         Commercial Joint Information Media Center Manager Phone Lines Center (JIC)
Technical Communicator EPIP RMT-2080-ENC/JIC-001, Activation and Operation of the ENC/JIC 26 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.1.4 Communications with field/offsite monitoring teams [per 10 CFR 50 Appendix E.9.c]
Emergency             Minimum            Primary Method      Primary Method       Backup        Backup      Planned or      Refer to Response          Communications         Described in site      Available        Method(s)     Method(s)     Potential     Following Facility              Links                E-Plan            following    Described in site Available  Improvement     Section for Assumed            E-Plan      following    Identified?    Additional LSNE?                         Assumed                    Information LSNE?
EOF                1 for each                Handheld Radio     Yes, Limited to         None         None    Satellite Phones      5.5 field/offsite                                radio reception monitoring team                              without CEP H.2.d repeaters OSC                1 for each                Handheld Radio     Yes, Limited to     None - EOF       None    Satellite Phones      5.5 Primary location   field/offsite                                radio reception      assumes from which field/  monitoring team                              without           command and offsite monitoring                                              repeaters           control after teams are                                                                           dispatched.
deployed EPIP RMT-2080-OSC-001, Activation and Operation of the OSC Attachment 6, Briefing Checklist 27 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.1.5 Communications with other Federal agencies as described in the site emergency plan (e.g., the US Coast Guard) [per 10 CFR 50 Appendix E.9.b]
Emergency             Minimum           Primary Method     Primary Method         Backup             Backup            Planned or           Refer to Response Facility    Communications        Described in site      Available         Method(s)           Method(s)            Potential         Following Links               E-Plan             following     Described in site      Available         Improvement         Section for Assumed             E-Plan            following           Identified?        Additional LSNE?                               Assumed                               Information LSNE?
Primary location     Coordination with         FTS, PSTN                No             PSTN                None           Satellite phones          5.2 where                Federal agencies communication with Federal agencies is performed Emergency

===Response===
Organization Directory Section 8 (Emergency Plan Phone Use Key &
Facility Maps) 28 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.1.6     Coordination and direction of on-site and in-plant response teams. This includes teams necessary to affect emergency repairs, firefighting, search and rescue, radiological monitoring, and implementation of Transition Phase coping and severe accident management strategies. To accommodate the timeline associated with NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (as discussed in Section 1), this element should be assessed in 2 phases.
4.1.6.1 Phase 1 Assessment Emergency                Minimum            Primary Method    Primary Method          Backup             Backup           Planned or                Refer to Response Facility       Communications         Described in site      Available          Method(s)         Method(s)            Potential              Following Links                E-Plan            following       Described in site     Available        Improvement              Section for Assumed              E-Plan            following          Identified?             Additional LSNE?                                Assumed                                   Information LSNE?
On-shift staff         Number necessary for the on-shift staff   PA, handheld                          PA, handheld       Yes - Voice CEP Table B-1          to perform Initial       radios and voice                      radios and Voice   Powered (CNP Staffing for      Phase coping             Powered                   Yes         Powered            Phones and          Satellite phones             Note 1 Radiological           actions (reflecting     telephones-                            telephones         handheld Emergencies            current staff &                                                                   radios) strategies) 1 each for:
                       - On-site radiological OSC and other          monitoring site-specific locations as           2 each for:                                                                       Yes - Voice necessary (The         - Firefighting (1 for    PA and                                PA and             Powered Fire Brigade and       brigade leader and 1     handheld radios           Yes         handheld           Phones and          Satellite phones               5.3 Work It Now            for OPS                                                                           handheld (WIN) Team).           representative)                                                                   radios)
CEP F.1.f              1 each per unit for:
                       - WIN Team 29 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.1.6.2 Phase 2 Assessment Emergency               Minimum           Primary Method       Primary Method      Backup             Backup               Planned or            Refer to Response            Communications        Described in site       Available       Method(s)         Method(s)                Potential      Following Section Facility                Links               E-Plan              following    Described in site     Available            Improvement         for Additional Assumed          E-Plan            following              Identified?        Information LSNE?                             Assumed LSNE?
Site-specific number    PA, handheld                Yes       PA and            Yes - Voice           Satellite phones           Note 1 needed to implement     radios and Voice                      handheld radios   Powered any 2 strategies        Powered                                                 Phones and OSC and other        developedtoinNRC       telephones                                               handheld radios) site-specific        response locations  as        repnet         R locatosasy.          Order Modifying necessary.           Licenses with Regard to Requirements for CEP F.1.f            Mitigation Strategies for Beyond-Design-Basis External Events 4.2       Plant Paging (Announcement) System The plant paging system is powered from a battery-backed source and would remain available to provide the initial emergency declaration and direction announcement to plant staff. No further action is required.
30 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.3 Communications Equipment at ORO Facilities Primary                   Backup                      Refer to Minimum          Primary Method        Method         Backup    Method(s)   Planned or      Following Emergency            minimum           Pribedyinethod       Available      Method(s)  Available     Potential    Section for Response Facility          Links                 E-Plan         following    Described in following  Improvement      Additional Assumed       site E-Plan Assumed      Identified?
LSNE?                     LSEE?                     Information Location where         At least one. See       Commercial             No           PSTN         No    Satellite phones     5.7 OROs receive           assumptions and       phone lines and notifications of an      discussion in           facsimile emergency                  NEI 12-01.
declaration or a Protective Action Recommendation (as described in the site emergency plan).
CEP F.1.a EPIP PMP-2080-EPP-1 00, Emergency
: Response, Attachments: 11 (MSP Notification) and 12 (Berrien County Sheriff Notification).
EPIP RMT-2080-EOF-001, Activation and Operation of the EOF, Attachments:
15 (MSP Notification) and 16 (Berrien County Sheriff Notification).
31 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.4     NOTIFICATION OF THE EMERGENCY RESPONSE ORGANIZATION (ERO) Emergency Plan Implementing Procedure PMP-2080-EPP-100, Emergency Response, paragraph 3.2.4 The ERO is notified using pagers. The Control Room initiates the notification process through a commercial provider. Telephones are used as a backup to the pagers. The paging provider maintains antennas on local communications towers. These systems are considered to be unavailable under the assumptions of this analysis. The ERO will self activate in the event of a large scale natural disaster if they cannot be contacted using the notification process.
4.5 EQUIPMENT LOCATION REQUIREMENTS Voice communications equipment has been determined to be survivable.
Spare radios will be stored consistent with these requirements. Exact locations have not been determined but will be determined upon completion of mitigation strategy for beyond-design-basis external events (FLEX) activities. (See Note 1) 4.6 PERFORMANCE CHARACTERISTICS (Post event with FLEX)
CNP emergency response facilities, including Security, have use of the 450 MHz handheld radios, PA system and satellite phones.
Field/offsite monitoring teams and the location controlling deployment of the teams (e.g., the EOF). Field teams are dispatched from the OSC and utilize handheld radios as the primary communications mode. They have cell phones and will also have satellite telephones as a backup.
The Shift Communicator, TSC and EOF Communicators, and the ORO contact points will communicate with a combination of radios and satellite phones.
ENS and HPN communications to the NRC staff are not dependent on site resources. The lines connect directly to the local phone company central office by way of buried conductors/pathways. The site will have satellite phones to use as a backup.
On-site teams and the location controlling deployment of the teams (e.g., the OSC): The OSC will have handheld radios for the dispatch and control of response teams. The Control Room is also equipped with a Voice Powered jack (telephone hand-set type) system and radios.
32 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 4.7      OTHER ASSESSMENT CONSIDERATIONS All radios and Satellite phones are provided with chargers and spare batteries.      Emergency Preparedness vehicles used by the field monitoring teams are equipped with radios powered from the vehicle electrical system.
Batteries for handheld radios have approximately 10 hours of charge. Chargers are locally powered and plans have been made to have a dedicated source of backup power and can be charged from portable generators provided by FLEX.
4.8       PERSONNEL TRAINING Response personnel should receive periodic training on the location and use of communications systems and equipment: Training programs will be updated to address emergency communications equipment consistent with implementation of CNP's mitigation strategy for beyond-design-basis external events (FLEX).
5.0      ADDITIONAL INFORMATION The following actions will be evaluated as a part of CNP's FLEX strategy:
a)        Provide  additional battery backup for the PA system.
b)        Provide  capability for hooking up alternate power generator for the intra-plant 450 MHz radio system.
c)        Provide  capability for hooking up alternate power generator for the public address system.
d)        Harden  exterior antennae to the extent necessary to provide reasonable assurance of survivability.
e)        Provide  survivable offsite 450 MHz radio system (including repeater and antennae) or portable repeater equipment.
5.1. Direct lines are provided linking the Emergency Facilities to the Berrien County Emergency Operations Center (BCEOC) and is provided with emergency power by way of an installed diesel generator. There are direct lines from: both Control Rooms, Central Alarm Station, Secondary Alarm Station and the EOF to the 911 dispatcher, which is located in the same building as the BCEOC. These are OPX (off premise extensions) powered by the Plant PBX.
These phones will be supplemented by satellite phones for the postulated loss of the public phone system infrastructure.
5.2. In addition to the ENS and HPN phones, there are two additional phone extensions included in the Control Rooms which are included in the emergency plan. These lines go directly to the local CO via underground transmission and bypass site PBX systems.
5.3. The CEP identifies the available methods of communications available to the various entities and facilities. The communications pathways include telephones, two-way radios, dedicated phones, FTS, Voice powered telephones, and the Public Address system.
5.4      -The Field teams use 450 MHz radios powered from the emergency vehicles. The range of these radios is limited to line of sight without a repeater but near plant readings would be useful in projecting any potential offsite radiation effects. With the use of a portable repeater or hardening of the existing repeater full capability is returned to the radio system.
33 to AEP-NRC-2012-83 Appendix B - NEI 12-01 Roll-Up 5.5      Paging (Public Announcement) System: The plant paging system is powered from an essential power bus. In the event of a loss of offsite power, provisions are made for the bus to automatically "seek" whichever bus is being provided with power from an emergency diesel.
5.6      Communications Equipment at ORO Facilities: The. Berrien County Emergency Operations Center (BCEOC) is provided with emergency power by way of an installed diesel generator. There are direct lines from both Control Rooms, Central Alarm Station, Secondary Alarm Station and the EOF to the 911 dispatcher, which is located in the same building as the BCEOC. These are OPX (off premise extensions) powered by the Plant PBX. These phones will be supplemented by satellite phones for the postulated loss of the public phone system infrastructure.
Note 1: Final planning for FLEX has not been completed, thus information concerning Mitigating Strategies communications requirements and portable emergency generators have not been finalized.
34 to AEP-NRC-2012-83 Implementation Timeline to AEP-NRC-2012-83                                           Page 1 of 3 Communications Assessment Implementation Timeline Completion                  Action                            Comments Date February 28,     Supplement direct telephone 2013             lines linking the CNP Emergency Facilities to the Lake Township Fire Department and the Berrien County and State of Michigan Emergency Operations Centers with satellite phones for the postulated loss of the public phone system infrastructure.
October 31,      Evaluate capabilities of off-2013             site radio communications including:
: 1. Verifying the ability of existing 450 MHz trunked radios to function in "point-to-point" mode.
: 2. Mapping of radio reception in the EPZ and to the Emergency Operation Centers without the repeater in service.
: 3. Assuring reasonable survivability for the off-site radio repeater and antennae.
to AEP-NRC-2012-83                                                          Page 2 of 3 Communications Assessment Implementation Timeline Completion                 Action                                 Comments Date July 31, 2014    Determine feasibility for the    To be evaluated as a part of CNP's FLEX strategy.
following future actions associated with FLEX:
: 1. Provide additional battery backup for the PA system.
: 2. Provide capability for hooking up alternate power generator for the intra-plant 450 MHz radio system.
: 3. Provide capability for hooking up alternate power generator for the public address system.
: 4. Harden exterior antennae to the extent necessary to provide reasonable assurance of survivability.
: 5. Provide survivable offsite 450 MHz radio system (including repeater and antennae) or portable repeater equipment.
September 30,    Provide alternate power          To be evaluated as a part of CNP's FLEX strategy.
2014             supplies for the following locations (assuming survivability) at a minimum:
: 1. EOF, which also has an existing diesel generator.
: 2. OSC to AEP-NRC-2012-83                                                          Page 3 of 3 Communications Assessment Implementation Timeline Completion                  Action                                Comments Date September 30,    Provide standalone UPS          To be evaluated through CNP's FLEX strategy.
2014             units for equipment in the EOF and TSC that will be needed to manage the emergency (computers, multi-line telephones and portable phones).
September 30,    Provide a dedicated source      To be evaluated through CNP's FLEX strategy.
2014             of backup power (portable generator) for charging batteries for handheld radios.
March 31, 2015   Update training programs to     To be performed as a part of the CNP's FLEX address emergency               strategy.
communications equipment consistent with implementation of FLEX.}}